CMS Releases CY 2022 Physician Fee Schedule Proposed Rule

On July 13, 2021, the Centers for Medicare & Medicaid Services (CMS) released the CY 2022 Revisions to Payment Policies under the Physician Fee Schedule (PFS) and Other Changes to Part B Payment Policies [CMS-1751-P] Proposed Rule, which includes proposals related to Medicare physician payment and the Quality Payment Program (QPP). Because Biden Administration CMS health officials were appointed late in the rulemaking cycle, the rule includes no sweeping policy proposals like the evaluation and management payment changes included the CY 2021 PFS proposed rule. This year’s proposed rule does include significant policy proposals addressing telehealth and other COVID-19 flexibilities, updates to the underlying practice expense data that will impact payment rates, policies promoting health equity, and enhancements and other changes to further develop physician quality initiatives.

Key takeaways from the CY 2022 PFS Proposed Rule:

• 2022 proposed physician conversion factor (CF) of $33.5848, representing a 3.75% reduction from the 2021 CF of $34.8931
• Extension of coverage to the end of CY 2023 for services temporarily added to the Medicare Telehealth Services List during the pandemic
• Update to underlying clinical labor cost data that may have a disproportionate positive impact on certain specialties with higher-than-average share of labor costs
• Health equity data collection initiative designed to give providers a more comprehensive understanding of health disparities impacting their patients
• Timeline to sunset the Traditional Merit-based Incentive Payment System (MIPS) by end of 2027

Comments on the proposed rule are due on September 13, 2021.

Read on for a topline summary of the major provisions in the proposed rule.

• The proposed regulations are available here.
• The press release is available here.
• The fact sheet is available here.

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For more information, contact Aaron Badida, Paul Gerrard, Deborah Godes, Sheila Madhani, Mara McDermott, Jennifer Ohn or Devin Stone.